| EU |
EU Taxonomy Regulation |
2020 |
a comprehensiver classification system designed to identify environmentally sustainable activities |
Banks and in-scope entities |
Failure to comply can result in reputational damage and exclusion from sustainable finance markets |
EU Taxonomy classification system |
| EU |
Corporate Sustainability Reporting Directive (CSRD) |
2023 |
'double materiality' approach; ESRS |
50,000+ EU/non-EU companies by 2027 |
Mandatory for EU/non-EU companies |
Aligns with IFRS S1 and S2 standards; TNFD metrics |
| EU |
Sustainable Finance Disclosure Regulation (SFDR) |
2021 |
financial institutions classify investment products based on their sustainability objectives |
Financial institutions |
Market exclusion for non-compliance |
Links to EU Taxonomy |
| UK |
Sustainability Disclosure Requirements (SDR) |
2023 |
ISSB-aligned reporting; Transition plans for Paris and GBF; Financed emissions disclosure |
Listed companies (from 2026); High-impact sectors (agriculture, mining) |
FCA enforcement starting 2026 |
Aligns with IFRS S1 and S2; References TNFD recommendations |
| US |
SEC Climate Disclosure Rule |
2024 |
Material climate risk disclosure; Scope 1-3 emissions reporting; Extreme weather cost reporting |
Public companies |
Delayed due to legal challenges |
N/A |
| US |
Climate Corporate Data Accountability Act (SB 253) |
2026 |
Scope 1-3 emissions reporting for $1B+ revenue firms; Biodiversity risk assessment |
Large corporations operating in California |
California state law enforcement |
Addresses supply chain biodiversity risks |